Strengthening Organic Enforcement Final Rule Published

January 18, 2023

For general questions about SOE, please fill out the form here. For specific questions about your operations and your certification, please reach out to your client services team

What is Strengthening Organic Enforcement? 

Strengthening Organic Enforcement or “SOE” is regulation from the United States Department of Agriculture (USDA) National Organic Program (NOP). 

The regulation has main objectives aimed at supporting the continued growth of the organic sector, mitigating fraud in organic, and ensuring organic integrity. The amendments will ensure consumers continue to trust the organic label.


  • SOE indicates anyone involved in the selling, trading, or brokering of an organic product must be certified. We are waiting to see how the regulation will rule on transportation and brand owners. 

Imports and Supply Chain: 

  • The regulation will require a National Organic Program import certificate to be associated with organic imports from all countries. 
  • SOE updates language around recordkeeping and Organic System Plans (OSPs). The new regulation will require a risk evaluation and fraud prevention plan for operators’ supply chains. 
  • SOE directs certifiers to share information on investigations and dictates certifiers must work together.

New Standards and Requirements: 

  • The regulation adds consistency for all certifiers and adds criteria, including internal control system requirements and certifier inspection requirements for grower group certification.
  • The regulation changes labeling for non-retail containers. Labels will require certifier identification, organic designation, traceability information, lot code, etc. Talk to your certifier about what may need to change on your non-retail labels. 

Certification Realm: 

  • The regulation will increase mandatory requirements for certifiers to update the Organic Integrity Database (OID) with specific data pieces more regularly and may require standardized certificates.
  • Onsite inspections will require traceability and mass balance audits. Many certifiers already do this, but it’s now written into the regulations. This update may increase inspection time. 
  • Certifiers will be required to perform risk-based audits. Certifiers must obtain audit documentation from operators to perform cross checks and supply chain analysis. 
  • The regulation will clarify that NOP’s investigation and enforcement authorities extend to all operations that violate the act, including uncertified operations and any “responsibly connected” persons to a certified operation.

Who will be impacted? 

Currently certified clients:  

All operators are expected to be affected by SOE, with increased required documentation, proof of NOP imports, changes in supply chain or labels. 

Uncertified brokers, traders, and sellers:
The new regulations will require the certification of anyone handling/in possession of an organic product. If you are an operator and are interested in becoming certified, please email us at 

Why does Oregon Tilth support Strengthening Organic Enforcement? 

The SOE proposal is the most substantial proposal by the NOP since the creation of the organic program. The proposed changes attempt to mitigate fraud and strengthen the integrity of the organic seal. This proposal will close loopholes in the current system and do more to keep out bad actors. We want to ensure the organic seal is not compromised and that organic growers and handlers are valued for their integrity. 


SOE is effective March 20, 2023, and full implementation is March 19, 2024.

Change can be daunting, but we’re here to help! For SOE questions specific to your operation, please contact your client services team. For general SOE questions, please fill out the contact form: 

Learn more:
Organic Trade Association Resources

Organic Grower Summit Educational Intensive 

Strengthening Organic Enforcement proposed rule 

Regulation Side by Side 

Contact Information

Oregon Tilth Main Office
PO Box 368
Corvallis, OR 97339
Phone: (503) 378-0690
Toll Free: (877) 378-0690

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